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Plymouth, South Hams & West Devon Local Planning Authorities' 2018, 5

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Plymouth, South Hams & West Devon Local Planning Authorities' 2018, 5 Plymouth, South Hams & West Devon Local Planning Authorities’ 2018, 5 Year Housing Land Supply Position Statement July 2019 Contents 1. Introduction ............................................................................................................................................... 2 2. What is the 5 year land supply? ............................................................................................................ 2 3. What is the Housing Delivery Test? .................................................................................................... 3 4. National Policy & Guidance - Demonstrating a 5 Year Supply ...................................................... 9 5. JLP whole plan delivery 2014-2019 & 5 Year Housing Land Supply Position (2019 monitoring point) ........................................................................................................................................... 11 Appendices Appendix 1. MHCLG letter confirming recalculated 2018 HDT measurement for the 3 JLP authorities Appendix 2. Plymouth LPA supply over the next 5 years (2019-2024) Appendix 3 South Hams LPA supply over the next 5 years (2019-2024) Appendix 4. West Devon LPA supply over the next 5 years (2019-2024) Appendix 5. Sites removed from 5 Year Land Supply (lapsed and undeliverable consents & sites considered developable not deliverable 2019-2024) Appendix 6. Amendments to past net additional dwelling delivery due to NPPF/NPPG changes regarding counting student and communal accommodation Appendix 7. List of Small sites in 5 year land supply Appendix 8. Small Sites Windfall Allowance – historic evidence Appendix 9. List of sites with consent for Communal Accommodation & list of losses forecast in the 5 YLS Appendix 10 Progress towards JLP Policy Area and LPA monitoring targets at 2019 monitoring point 1 1. Introduction 1.1 This position statement presents the five year housing land supply position for the Joint Local Plan (JLP) Authorities1 as of 31st March 2019 for the five year period from 1st April 2019 to 31st March 2024. It sets out an updated methodology and five year land supply calculation based on the relevant changes in the: revised National Planning Policy Framework (NPPF) published 19th February 20192, updates to the National Planning Practice Guidance (NPPG) published 13th September 2018 and subsequently amended on 22nd July 2019, and the publication of the 2018 Housing Delivery Test results. 1.2 The Plymouth and South West Devon Joint Local Plan (JLP) was adopted by South Hams District Council on 21st March 2019, Plymouth City Council on 26th March 2019 and West Devon Borough Council on 26th March 2019. As a result of adoption of the JLP in March 2019 the council’s 2018 Housing Delivery Test result has been revised and then 2019 5 Year Land Supply (YLS) is position is now set against the Housing Requirement in the JLP. This report therefore sets out the new position in light of the adoption of the JLP. 2. What is the 5 year land supply? 2.1 The NPPF was revised and published in February 20193. Paragraphs 67 and 73 of the NPPF require local planning authorities to identify a 5 year supply of deliverable sites. Paragraph 73 specifically states: “Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirements set out in the adopted strategic policies, or against their local housing need where strategic policies are more than five years old. The supply of specific deliverable sites should in addition include a buffer (moved forward from later in the plan period) of: a) 5% to ensure choice and competition in the market for land; or b) 10% where the local planning authority wishes to demonstrate a five year land supply of deliverable sites through the annual position statement or recently adopted plan, to account for any fluctuations in the market during that year; or c) 20% where there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned housing supply.” 1 Plymouth City Council, South Hams District Council and West Devon Borough Council 2 The NPPF was further amended on 19th June 2019 to remove paragraph 209a which has no bearing on the policy and guidance associated with this Housing Position Statement, the 5 Year land Supply and Housing Delivery Test 3 See footnote 2 2 What is the starting point for the JLP authorities to demonstrate a 5 Year Land Supply? 2.2 The revised NPPF and NPPG4 make clear that the starting point for calculating the 5YLS is the Housing Requirement figures identified in strategic policies provided they are less than 5 years old or more than 5 years old, but have been reviewed and are found not to need updating. In other circumstances the starting point for calculating the 5 YLS will be the Government’s new standard method for ‘Local Housing Need’ (LHN). 2.3 As the JLP has recently been adopted (March 2019) the Housing Requirement within the JLP is the starting point for calculating the 5 YLS figure and therefore the 5 year land supply is no longer set against the Government’s new standard method for ‘Local Housing Need’ (LHN). 3. What is the Housing Delivery Test? 3.1 The government have introduced the Housing Delivery Test (HDT) to determine Local authorities’ performance against its new standard method for LHN or adopted plan housing requirement (whichever is the lower). The HDT measures5 in percentage terms the net additional dwellings provided in a local authority area over the past three years against the lower of the Adopted Housing Requirement or the authority’s LHN over the past three years. 3.2 The Secretary of State published the 2018 HDT results for each local authority in England in February 20196 and the NPPF indicates that the Secretary of State will publish the results every November. As the publication of the HDT results preceded adoption of the JLP, the results published related to each Local Planning Authority individually. 3.3 The HDT has the following policy consequences 1. If delivery falls below 95% then an Action Plan must be published. 2. If delivery falls below 85% then a 20% buffer should be added to the five year supply7 3. If delivery falls below 75% then there is a presumption in favour of sustainable development8 4 NPPG paragraph 030 Reference ID:3-030-20180913 5 The method for calculating the HDT measurement is set out in the HDT measurement rule book https://www.gov.uk/government/publications/housing-delivery-test-measurement-rule-book Further details of the HDT and its implications are contained within the NPPG https://www.gov.uk/guidance/housing-and-economic-land-availability-assessment 6 https://www.gov.uk/government/publications/housing-delivery-test-2018-measurement 7 The buffer to be applied to the 5 year supply is now set by the result of the HDT 8 NPPF paragraph 11d and footnote 7 3 3.4 There are however transitional arrangements in place in relation to the application of the presumption in favour9 and this is set out in Annex 1 of the NPPF. For 2018 the presumption in favour would apply the day after the publication of the HDT10 if delivery falls below 25% and for 201911 it would apply if delivery falls below 45%. HDT Calculation - Total net homes delivered over the last three years 3.5 The HDT measurement rulebook explains that the number of net homes delivered to be used in the HDT (which is measuring delivery against plan requirement and LHN) is the National Statistic for net additional dwellings12 with adjustments for net student accommodation and net other communal accommodation.13 How to count student cluster flats and communal accommodation? 3.6 As a result of the guidance contained in the HDT measurement rulebook it is now the case that student cluster flats are to be counted as single dwellings14 against plan requirement and LHN figures. Furthermore the Government has also introduced ratios to be applied to student communal and other communal accommodation15 which are also to be counted against plan requirement and LHN. 3.7 As the HDT applies to the past three years the Government has required Local Authorities to make adjustments to the net supply statistics retrospectively to account for the changes introduced in the guidance. The three JLP authorities have therefore adjusted their past delivery figures and future supply figures to ensure it complies with the requirements of the HDT and is consistent with the NPPF/NPPG. The amendments and implications for each authority individually and collectively are set out below in the HDT result and 5 year supply position statement for the JLP authorities. HDT Calculation - Total number of homes required over the last three years Housing requirements more than five years old 3.8 The HDT measurement rulebook indicates in paragraph 14, that where the latest adopted housing requirement figure is over five years old the figure used will be, for areas with a 9 NPPF paragraph 11d and footnote 7 10 19th February 2019 11 HDT to be published in November 2019 12 https://www.gov.uk/government/collections/net-supply-of-housing published by MHCLG annually in November 13 As defined in the Housing Flow Reconciliation (HFR) guidance notes at https://www.gov.uk/guidance/dwelling- stock-data-notes-and-definitions-includes-hfr-full-guidance-notes-and-returns-form 14 Provided they meet the government definition of a dwelling 15 Not previously accounted for in the JLP authority statistics
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